POLITYKA PRYWATNOSCI

PRIVACY NOTICE

Summary

We respect your right to privacy and treat the personal data you give to us with care and we act according to the European Regulation 2016/679 (GDPR) for the protection of the personal data and the Greek Legislation. This Privacy Policy describes how we collect, use, share, store or otherwise process the information we hold about you. We are committed to ensuring the personal data you provide is used for the purpose it was collected and is kept secure.

We encourage you to read this Privacy Notice carefully when using our website or services or transacting business with us. By accepting this Privacy Notice you are informed and you provide your free, informed, specific and unambiguous consent for the personal data you provide on the website at https://www.atrium.gr/

Your personal information allows us to provide the products and services you have asked for, as well as enabling us to improve those products and services by understanding your interests and preferences.

Please note that Atrium Hotels is the Data Controller of your personal data. PRESIDENTIAL and AITHRION PALACE, (Greece) Limited (“we”, “our”, “us”) is the data controller when you provide information to any of our brands, including: Atrium Platinum, Atrium Palace and Atrium Prestige.

The principles set out in this Privacy Notice apply to all instances in which Atrium Hotels receives your personal data as a Data Controller for the purposes described in this notice. Those purposes are processing of data in order to participate in the various activities available on this website or as mentioned below.

If you have any questions about our privacy practices, please refer to the end of this Privacy Notice for information on how to contact us.

What information do we collect?

Atrium Hotels is the only Data controller of these data. The term “personal information or personal data” in this Policy refers to information that identifies or is capable of identifying you as an individual.

We do not sell, rent or otherwise disclose personal information collected by us to third parties in the ordinary course of business. The use of information collected through our website shall be limited to the purpose of providing the service for which you have engaged us.

When you interact with our products and services, for example when browsing our website or booking a hotel room οr you filling in any contact form, we collect information about you and that particular interaction.

Generally, the types of personal data that we process may include:

1. Data provided by users for making reservations, both through our website, the call center, the contact form on our website and emails for room bookings and combined packages (airline tickets and room bookings):

When referring to the notions of “special categories of personal data” or “sensitive personal data”, it means that this kind of personal information reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and genetic data, biometric data which allows to uniquely identify a natural person, health data and/or data regarding sexual orientation. At Αtrium Ηotels, we do not collect sensitive personal data, unless you provide us them along with an explicit consent for every related purpose of processing. Such a case is when we ask you to provide us information about your health (i.e. allergies), in order to be able to offer you the best gastronomic services in relation with your health status. This information is stored securely with restricted access and handled with the greatest respect for your privacy. Where you provide information to us about other people, you need to make sure you have their permission to do so or that you can speak on their behalf, for example, in the case of children.

What is the purpose of collecting such personal information?

The justification for processing your personal data will be as follows:

for making reservations, both through our website, the call center the contact form on our website and emails for room bookings and combined packages (airline tickets and room bookings): performance of the contract between the parties. The use of the Website, is to provide an online booking service (room or flight) to its users (legitimate interest of Atrium Hotels)

for changing or cancelling their reservations: the performance of the contract between the parties. The use of the Website, is to provide its users with the opportunity to amend or cancel their bookings (legitimate interest of Atrium Hotels).

for sending newsletters: the consent provided by the user. However, if the user withdraws its consent, this will not affect the legality of prior processing.

for submitting employment applications: the consent provided by the user. However, if the user withdraws its consent, this will not affect the legality of prior processing.

How we keep your personal data secure

We take all the necessary precautions, security measures as well as the relevant technical and organizational measures to ensure the confidentiality of the provided personal data. We have secure systems and processes in place to ensure the personal information you provide us is kept safe. We store personal information on our secure electronic systems. We can assure you that we take all reasonable steps to ensure your data is handled securely under appropriate agreements with our suppliers.

Minors Data

At Atrium Hotels, it is not part of our policy to seek or obtain personal data directly from minors (i.e. under the age of 18) without their parental or legal guardian’s consent. However, as it is impossible to always determine the age of persons who access and use our websites, we encourage parents or guardians to contact us if they notice any case of unauthorized data provision by minors in order to exercise accordingly their rights such as deletion of their data.

How we use the data we collect from this website?

We always base the processing of your personal data to a valid legal basis such as law, contract or your explicit consent etc.

We need your personal data in order to:

a. Comply with legal obligations:

Verify your identity

Monitor the use of our products and services and content

Facilitate administration and marketing purposes including analyzing your travel and accommodation preferences, as well as communication purposes in relation to our products and services our strategic marketing partners, and other trusted third parties (ELSTAT)

send you product or service related communications, service messages (Law 3471/2006)

b. Enter a contract or fulfill the hospitality contract we have with you:

Provide you with help and support where it may be required. For example, we may contact you to provide assistance if experience technical difficulties, where we have your contact details

Provide you with the products and services you have requested, including administering your booking, amend it or cancel it, responding to any enquiries, complaints or requests you may have

Verify your identity

Process a transaction (i.e. completing a reservation, responding to a request for information etc)

Detect ad blockers and other technologies that affect the services we provide

Send you product or service related communications, service messages

Offer you the opportunity to work with us and become a member of our hospitality team

c. Promote the legitimate interests of Atrium Hotels:

In order to help you enter a contract with us or to fulfill the hospitality contract we already have between us. (Verify your identity, provide you with the products and services you have requested, including administering your booking, amend it or cancel it, responding to any enquiries, complaints or requests you may have)

Improve our services as well as promote questionnaires or surveys in order to provide you personalized offers about our products and services;

Make decisions about what direct marketing to show you based on how you have interacted with us

Monitor the use of our products and services and content

Improve our products and services online and offline, including our websites and apps

Comply with legal obligations on us

Keep guests safe and ensure the security of our hotels

Offer you personalized information about us and special offers, goods, services any events that may interest you or/and send you direct marketing, where you have consented

Facilitate administration and marketing purposes including analyzing your travel and accommodation preferences, as well as communication purposes in relation to our products and services our strategic marketing partners, and other trusted third parties (ELSTAT)

However, for certain activities we may also need your explicit consent to process your data. Where the consent is needed for the processing it is clearly mentioned in this Privacy Notice.

In addition to sending you information about the products and services you use (product communications) and in-life communications while you stay with us, where we have your permission or where we are relying on our legitimate interest, we may send you direct marketing communications about our products, services, events and offers.

Direct marketing communications may be sent by post, email, telephone, SMS and MMS, through social media (such as Whatsapp, Instagram, Twitter, and Facebook), messages including push notifications to your mobile devices, and via other electronic means such as when you visit our websites or use our apps. This may also include any websites and apps of our partners who are in our advertising networks.

We may send you direct marketing while you have an ongoing relationship with us and for a reasonable time after you have used one of our products or services where we feel we have a legitimate interest.

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing, or profiling we may carry out for direct marketing, at any time. You can do this by contacting us using the details set out in the end of this Privacy Notice.

How long do we keep your personal data?

We will retain your information for as long as necessary for the uses set out in this Policy or while there is a legitimate business reason for doing so. If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. Your information will be retained in order to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any monies owed, and to resolve disputes.

More specifically,

for making reservations, both through our website, the call center, the contact form on our website and emails for room bookings and combined packages (airline tickets and room bookings): the data will be stored throughout the contractual relationship, and after termination of the same, for the limitation period for legal actions that could result from it.

for changing or cancelling their reservations: will be stored throughout the contractual relationship, and after termination of the same, for the limitation period for legal actions that could result from it.

for sending newsletters: will be stored for as long as the user does not withdraw the consent provided for this.

4.for submitting employment applications: if your application for employment is unsuccessful, the organisation will hold your data on file for 12 (twelve) months after the end of the relevant recruitment process. If you agree to allow us to keep your personal data on file, we will hold your data on file for a further 6 (six) months for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data is deleted or destroyed. You will be asked when you submit your CV whether you give us consent to hold your details for the full 18 months in order to be considered for other positions or not.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper based) and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

Your rights

As a data subject, you have a number of rights. You can:

access and obtain a copy of your data on request; You may request a copy of your personal information which we may hold about you by getting in touch with us using the contact details below. You may also ask us to correct any inaccuracies in your personal information. This right may be restricted by law where disclosing information may result in the personal information of other individuals being disclosed and it would be unreasonable to do so.

require Atrium Hotels to change incorrect or incomplete data;

require Atrium Hotels to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and

object to the processing of your data where Atrium Hotels is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights, please contact Atrium Hotels at dpo@atriumhotels.gr

We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.

In some cases, we may be required to disclose your personal information to comply with legal requirements and requests from government agencies if required for the purposes set out above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Your information will only be shared and used in accordance with this Policy and where an agreement is in place to ensure that your information is protected. We won’t sell your personal information without your consent or share it with other organisations for their own marketing purposes.

We may also disclose your personal information to our group companies or to third parties:

We may share your personal data:

with our group companies and affiliates, all within the hotel sector, which require access to your data for correct provision of the chosen services.

with our advertising networks and partners, commercial partners (including but not limited to owners of hotel businesses we manage or to whom we have licensed a brand and/or hotel system), and sharing with our suppliers.

with third-party payment processors, payment service providers, IT and marketing support service providers and other consultants, vendors and service providers who need access to such information to carry out work or provide services on our behalf or who help us to provide these services to you;

with anyone involved in the process of making your travel arrangements (e.g. travel agents, group travel organisers and your employer) in order to fulfill contractual obligations;

with any law enforcement, courts, Government or regulatory bodies (in whatever jurisdiction), or otherwise in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, court order or legal process;

if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of our hotel or any third parties

in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company, or any change of management of a hotel;

with our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;

with any other party at your consent or at your direction; and

otherwise as permitted or required by applicable laws and regulations.

User data may be disclosed to:

data provided for making reservations, both through our website, the call center, the contact form on our website and emails for room bookings and combined packages (airline tickets and room bookings): with the Companies belonging to or affiliated with Atrium Hotels, all within the hotel sector, which require access to your data for correct provision of the chosen services. The sole purpose of this communication will be to be able to provide the services to your correctly.

data provided for changing or cancelling their reservations: with the Companies belonging to or affiliated with Atrium Hotels, all within the hotel sector, which require access to your data for correct provision of the chosen services. The sole purpose of this communication will be to be able to provide the services to your correctly.

data provided for sending newsletters: will not be disclosed to third party companies.

data provided for submitting employment applications: will not be disclosed to third party companies. We will share your information within our group of hotels (Atrium Platinum, Palace, Prestige), solely for internal administrative purposes and/or for the purposes of employment.

Our site may contain links to other websites belonging to third parties. We do not control the privacy practices of these other websites. You should therefore make sure when you leave our site that you have read that website’s Privacy Notice.

Overseas Transfers of Your Personal Data

Your personal data will be stored at our hotel in which you stay or visit. Alternative, your personal data will only be shared with one or more hotels of Atrium Hotel’s Group Companies. Your personal data will not be transferred to countries outside the EU.

In case we may need for some reason to transfer such data, we will only transfer such data in countries that satisfy the adequate or comparable levels of protection in order to protect personal data held in that jurisdiction, and (where we are required to do so) with your consent.

In case personal data is transferred from the EU to outside the EU, we use Model Clauses, ensuring that such data transfers are compliant with applicable privacy legislation.

The information you provide to us may be given to our third party service suppliers outside the European Economic Area for the purpose of delivering the personalized services and communications stated above. Atrium Hotels will always take steps to ensure that your information is used by third parties in accordance with this Privacy Notice and that your information is kept secure at all times. In particular, in relation to any transfer to a third party in a country that is not subject to an adequacy decision by the EU Commission, such transfer will be appropriately protected through mechanisms such as EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review upon request.

Our processors

There may be situations where we use data processors – companies who act on our behalf – to collect your information for us or to use the personal data we pass to them to provide your service. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.

Travel agents and partners

We collect information about you when it is provided to us by third parties. This might include online travel agents, travel websites, and other partners. This could be when you make bookings, review your stay online, or where you interact with anyone who promotes our brands. You should always read the privacy policies of travel companies or other third parties you use, as they will use your information in accordance with their own privacy policies.

When you, or someone on your behalf, make a booking using travel agent, booking platform or other third party to use our services, they may pass us information about your booking, including information about anyone else on that booking. The same would be true where you use a third party to make inquiries about our products or services.

Where you interact with third parties who promote our services for us, these third parties may pass us your information.

We may also obtain information about you from our partners and other companies that have your permission to share your information both online and offline, like insight providers.

Do not track signals or browser/device settings

Our websites are not designed to respond to “do not track” signals or browser/device settings.

Analysis and product development

We may use your information to improve the products and services we offer. For example, we may look at the preferences our guests have when they stay with us to offer more relevant personalised services to them.

Linked services, third party sites and content

Our website may, from time to time, contain links to other websites which are outside of our control and are not covered by this Policy. We do not accept any responsibility or liability for other sites’ privacy policies. If you access other websites using the links provided, please check their policies before submitting any personal information.

Cookie Policy

Our site uses cookies. A “cookie” is a small file of letters and numbers that is sent to your computer by a website and automatically saved on your computer by your web browser (e.g. “Internet Explorer”). Each time you request a page from the website, your web browser sends this cookie back to the website server.

You are not obliged to accept cookies. If you wish, you can set your browser to notify you before you receive a cookie so you have the chance to accept it and you can also set your browser to refuse to receive or send all cookies. The website www.allaboutcookies.org contains step-by-step guidance on how cookies can be switched off by users.

For more information about our cookie policy visit: ….

Please note that our advertisers and third party partners may also use cookies. These parties may use so-called “third party” cookies so that they can track your response to their adverts and/or identify you on any other website that you visit which also contains their adverts. Please refer to their Privacy Notice for further details.

Social media login

Our websites and apps provide plug-ins to social media websites, including Facebook, Twitter, Youtube, and Instagram.

If you make use of, or log-in to, the social media features on our websites or apps, we may (depending on your privacy settings) access, use and store information about you, including, but not limited to: your name, e-mail address, gender, location, profile, picture, contacts, and any other information you have chosen to make available.

To find out more about the reasons and extent to which social media sites collect and process your data, or to change your privacy settings, please refer to your social media provider’s privacy policy.

Changes to our Privacy Policy

From time to time we may make changes to this Policy. This might be in relation to changes in the law, best practice, changes to the services we provide or collection and use of your personal information. We will always display clearly when the Policy was last updated and where appropriate, notify you of any relevant changes.

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